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Strategies to Managing Risks in Real Time in the Absence of Standards: Case Study of a PFAS Release to a Riverine Environment
Tiana Robinson, Stantec Consulting Limited
The objective of this presentation is to present a unique case study of an unconventional, multi-pronged site strategy developed in response to a release of PFAS-containing firefighting foam and other contaminants to a riverine environment.  

Per- and polyfluoroalkyl substance (PFAS) compounds are quickly becoming known as “forever compounds”, and as regulators rush to develop guidelines for various media and understand their toxicity, assessors and researchers strive to understand their fate and transport in various environments. These two key components need to be brought together in order to effectively manage risks and develop site strategies, particularly in dynamic environments such as aquatic ecosystems. An additional challenge comes when there are regulatory and public pressures to make rapid site strategy decisions based on limited information.

This presentation will present a unique case study of an unconventional, multi-pronged site strategy developed in response to a release of PFAS-containing firefighting foam and other contaminants to a riverine environment. The fire involved the ignition of rubber at an industrial facility. The run-off from the firefighting activities entered the storm sewer system and discharged to a nearby creek that drained through a largely agricultural area. Public and regulator concern for both human and ecological receptors was high, and regulatory orders were promptly issued. This spawned an emergency containment program, along with the rapid assessment of surface water and potable groundwater impacts to help define the extent and magnitude of the release and inform future containment and clean up actions. Selected PFAS compounds and other contaminants were found in surface water several kilometres downstream of the site, necessitating surface water management measures to mitigate further spread, and implementation of a robust surface water sampling and assessment program. While this program facilitated defining the contamination extent, challenges to site decisioning arose from knowledge gaps related to PFAS fate and transport, PFAS toxicity to aquatic communities, additive toxicity from PFAS and other contaminants, and other potential historical contaminating activities in the area that could have been contributing to the observed contaminant signature. As such, the need for additional clean-up and/or risk management in response to the fire release was uncertain. Given that active remedial strategies for aquatic environments (e.g., dredging, containment) are costly, intrusive and can have a reduced net environmental benefit compared to a longer-term, natural recovery solution, a multi-pronged site assessment and management strategy was then developed as follows:

Evaluation of background conditions to establish the limits of the contribution of the fire to the contamination. This helped to reduce the footprint requiring management/remediation.
Completion of a risk evaluation that combined incidental observations and available toxicological literature values to assess the potential for risks to the aquatic community.
Implementation of a longer-term monitoring program of both surface water and sediment over time to confirm the natural recovery of the system In addition to providing a sustainable and long-term solution to assessing and managing the contamination from the fire, this strategy proved effective at addressing public and regulatory concerns, limiting remedial costs, and advancing the site towards closure in a reasonable timeframe.

Tiana Robinson, Senior Hydrogeologist, Principal and Discipline Leader, Stantec
Tiana Robinson is a Senior Hydrogeologist, Principal and Discipline Leader based out of Stantec’s Waterloo office. She has over thirteen years’ experience in site management and remediation; conducting and managing environmental site assessment; soil, sediment, and groundwater remediation; contaminant hydrogeology; excess materials and waste management; spill response; and, risk assessment projects in a variety of client service areas across Canada and the U.S. Through these projects, Tiana has fulfilled multiple roles, including technical lead, project management, client management, regulatory and stakeholder consultations, and litigation support. She holds a B.Sc. in Geology from the University of Minnesota and an M.Sc. in Earth Sciences from the University of Waterloo. Tiana is a Qualified Person Environmental Site Assessments under Ontario Regulation 153/04 and is registered as a Practicing Member of the Association of Professional Geoscientists of Ontario and the Association of Professional Engineers and Geoscientists of Alberta.

Managing the Risks of PFAS at Airports – Lessons Learned from North America and Australia
Douglas Smith, Etienne Bordeleau, Jessica Hannaford
The objective of this presentation is to provide an overview of the considerations with respect to managing PFAS, including: source prioritization, managing legacy AFFF and foam substitution, regulatory uncertainty, risk communication and risk mitigation.  

The recognition of per- and polyfluoroalkyl substances (PFAS) as emerging contaminants at airports presents unique challenges to decision makers tasked with managing environmental liabilities. PFAS are key ingredients in aqueous film-forming foams (AFFF), which are used as fire suppressants during training and during emergency response actions and have been essential to airports in protecting safety. In a time of such regulatory uncertainty and rapidly evolving science regarding the risk of PFAS compounds, decision makers are looking for effective strategies to determine the risks and potential liabilities, and to develop effective and pragmatic solutions.

Critical to making informed decisions is the need to understand the issue from several perspectives. One must consider not only the toxicology of the PFAS compounds, but also the release mechanisms, site characteristics (i.e., topography and geochemistry), and the potential risk exposure pathways through which PFAS may be transported through the environment. The risks to human health and the environment are still the subject of much research, and only limited information are available on the toxicity of most PFAS compounds, including short-chained compounds, which are often used in non-AFFF foams. To exacerbate these challenges, the widespread media coverage, high level of public interest and elevated level of regulatory scrutiny means that timeframes are compressed and a rapid and flexible approach is required to inform the decision-making process.

Presently, the options to effectively treat PFAS impacted wastewater or groundwater are limited. Granular activated carbon (GAC) and anion exchange have been the most commonly implemented technologies. Both technologies result in the production of PFAS containing waste materials that require careful disposal. To further compound the issue, the persistence and high solubility of PFAS means PFAS releases at the site could offset years of treatment effort. Complicating the issue is the potential for new impacts through continued use of legacy AFFF products. Effectively managing the legacy foam products or equipment that may be impacted by PFAS from historic use of AFFF is equally challenging, as there are limited cost-effective solutions to clean equipment or to destroy PFAS.

Using case study examples to demonstrate the lessons learned from work at airports in North America and Australia, this presentation will provide the audience with an overview of the multi-disciplinary considerations with respect to managing risks of PFAS, including:

• Source identification and prioritization;
• Managing risks from legacy AFFF and foam substitution;
• Managing risks with respect to regulatory uncertainty;
• Managing risk communication; and,
• Managing risk mitigation measures, including available treatment options.

Douglas Smith, Service Line Leader – Contamination Assessment and Remediation, GHD
Douglas Smith is a professional geoscientist (Ontario) and project manager with more than 17 years of experience in the environmental consulting industry. Doug leads GHD’s North American Contamination Assessment and Remediation Service Line and our North American Emerging Contaminants working group, driving the collaboration and sharing of technical knowledge across the GHD global network for investigation, risk management, and remediation approaches for constituents, including PFAS. Having completed a 2.5-year internal transfer to Sydney, Australia, Doug brings back to Canada, the lessons learned from Australia with respect to PFAS.

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